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Showing posts for tag: RCRA
2/25/2014
Management Strategies for Using RCRA Exclusions
At first glance, managing hazardous waste in a way that relieves the generator from some RCRA regulations may seem very appealing. In some cases though, these management strategies may not provide as much relief as initially believed and may make subsequent management decisions even more difficult. One scenario that raises this challenge is the EPA’s exclusion for certain de-characterized hazardous wastes...
1/28/2014
Simplify Your Approach to Waste ID
Identifying hazardous waste and assigning waste codes is one of the most complex responsibilities in waste management. Many factors need to be considered when making this determination, including the waste’s properties, the hazards it poses, and even the industry in which it was generated.
The EPA’s Resource Conservation and Recovery Act (RCRA) regulations provide a complex system of lists that personnel must use to...
12/31/2013
Top Compliance Articles of 2013
For the annual year-end edition, we’ve collected the most popular articles from 2013, covering the major happenings that may have affected your facility. From new rulemakings and requirements to tips on inspections and help planning for next year, these compliance articles stood above the rest....jpg?width=819&height=630&ext=.jpg)
12/30/2013
Plan Ahead for 2014 Biennial RCRA Reports
As the 2013 calendar year winds down, hazardous waste generators begin buttoning up their recordkeeping for the current year and planning for 2014. This process most likely includes confirming that all facility personnel completed their annual training, all manifests are accounted for, all waste and LDR determination records are in order, and their contingency plan is current. In addition to the usual year-end wrap-ups, this year...
11/26/2013
New RCRA Exclusion for Solvent-contaminated Wipes
On July 31, 2013, at 78 FR 46448, the United States Environmental Protection Agency (EPA) promulgated a new final rule to relax hazardous waste management requirements for solvent-contaminated wipes (i.e., shop towels). Solvent-contaminated wipes that are laundered will be conditionally excluded from regulation as solid waste. Solvent-contaminated wipes that are discarded will be...
10/22/2013
Cutting Costs With Life Cycle Assessment
Life Cycle Assessment is a critical tool for organizations seeking ways to reduce their environmental impact, manage waste more efficiently, and reduce compliance costs. Also called life cycle analysis or “cradle-to-grave” analysis, a Life Cycle Assessment (LCA) is designed to gauge how a product will impact the environment throughout its life—from the initial sourcing of raw materials to eventual waste disposal...
9/24/2013
Understanding Derived-from Rule Exclusions
Under the Resource Conservation and Recovery Act (RCRA), solid waste generated from the treatment, storage, or disposal of hazardous waste remains hazardous waste unless excluded elsewhere in the regulations. This is known as the “derived-from” rule and is designed to ensure that wastes that are treated, but which may still pose a threat to human health or the environment, do not fall through the cracks of RCRA regulation...
8/27/2013
Manifesting State-specific Hazardous Waste for Interstate Shipments
Shipping hazardous waste between states can be more complex than it seems. Under Section 3006 of the Resource Conservation and Recovery Act (RCRA), each state is authorized to oversee its own hazardous waste management regulatory program, as long as the state’s rules are at least as stringent as the Federal regulations. While most states simply adopt the Federal hazardous waste management rules, a handful of states...
7/24/2013
Identifying Underlying Hazardous Constituents (UHCs)
One of the most confusing aspects of the land disposal restrictions is the determination of underlying hazardous constituents (UHCs). UHCs are trace amounts of hazardous chemicals (listed in 40 CFR 268.48) found in some hazardous wastes that do not in and of themselves cause the waste to be hazardous, but must be treated before the waste is deposited in a landfill. Due to a convoluted legal history, pre-disposal treatment for UHCs is...
6/25/2013
State-level Variations for Satellite Accumulation Areas
Under the Resource Conservation and Recovery Act (RCRA), each state can operate its own hazardous waste regulatory program in lieu of Federal EPA standards. State-level programs must be at least as stringent as Federal regulations, but even when the rules are identical, the implementation can vary...
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